Evaluation of your environmental performance

Section 25(4)(b) of the Act includes a requirement for evaluation of the effectiveness of controls. You should conduct a performance evaluation on a regular basis including after each environmental event or change in activities. This will provide you with information that you will use to understand, demonstrate, and improve your environmental performance. The frequency of monitoring must be set to reflect the level of risk associated with that activity.

The monitoring program should include preventative measures to track indicators that might identify forthcoming issues. It should also identify triggers for additional or non-routine monitoring during upset conditions, or after identification of disparate results.

As noted earlier, you will select the actions you take according to the scale and potential risks to human health and the environment of your activities. Information that you use during your performance evaluation may include, but not be limited to:

• monitoring results;
  • non-compliant results;
  • trends in results;
  • reliability of results – can they be verified, are unusual results checked;
  • usefulness of results (might your monitoring benefit from changing the frequency, location, or type of monitoring);
• records of incidents;
• compliance audit results;
• maintenance records;
• environmental complaints or feedback;
• correspondence with external interested parties such as EPA, WorkSafe, local council; and
• suggestions or observations of company personnel.

The monitoring results must be presented in a manner so that their meaning is transparent. When you are reviewing your results you might want to make it easier to visualise trends by presenting them as a graph or bar histogram, rather than just raw numbers.

You must also conduct a quality control assessment of the monitoring results to ensure they are reliable. This assessment might include checking of completion of required instrument calibration, instrument quality and maintenance, suitability of instrument calibration reference standards, competence of personnel conducting the monitoring, consistency of results obtained by different operators, security of monitoring results, investigation of aberrant results (outliers), or changes to equipment at the monitoring point.

The results of your environmental performance evaluation can be used for a wide range of opportunities, not just licence compliance. Such uses may include:

• demonstrating you are meeting the GED;
• demonstrating compliance with regulatory controls (including your EPA licence);
• assessing the efficacy of your environmental protection procedures;
• assessing the efficacy of your environmental protection equipment;
• identifying improvement in environmental performance following modification of plant to improve environmental performance;
• assessing the impacts of change in process streams (verification of the expectations you had for the change);
• identifying opportunities for more efficient use of resources;
• identifying opportunities for reduced production of waste;
• verifying and refining the environmental aspects and impacts you use during the risk assessment;
• confirming the suitability of your environmental performance indicators;
• establishing performance benchmarks to compare future performance against;
• identifying opportunities for improvement in training; and
• assessing the long-term impacts of environmental incidents and the corrective actions taken to manage those incidents.

Plant and environmental control equipment maintenance

Where you rely on engineering controls (plant and equipment) for risk mitigation you must ensure that those controls are appropriately maintained, and their effectiveness optimised. If they are static structures such as bunds, grease traps, or triple interceptor traps, they must be emptied and checked to ensure they have not been damaged since the last inspection. You should also check that they still have sufficient capacity for activities within their catchment – that they have been emptied and maintained at a sufficient frequency.

Mechanical emission control equipment, such as air scrubbers, sump pumps or step screens, must be included in a regular inspection and preventive maintenance program. Waiting until they fail before they are repaired is not acceptable practice. The more critical the equipment, the more frequent the inspections should be. You should also take into account the reliability of the plant when reviewing the maintenance schedule. Larger facilities have an asset management system that should include a suitable inspection and preventative maintenance schedule.

Change management

Your operational controls should be based on the findings of your latest risk assessment. However, these findings will become out of date once there are any changes to activities or plant at your activity site. The changes can involve such things as equipment or process upgrades, plant throughput, raw material usage (type and volume), materials storage, relocation of activities within the site, transport methods (e.g. from IBCs to road tankers), staff changes, etc.

Changes must be managed and documented to ensure that any changes made do not compromise risk management controls or introduce a new risk that itself requires control.

In addition to operational changes you should also consider the impacts of decommissioning a process or equipment to ensure risks to human health and the environmental are identified and managed.

Examples of potential consequences are:

• demolition of the plant removes an environmental control you relied on to control emissions from another section of the activities – such as removal of a section of bund wall, or air ducting;
• you now have more hardstand to manage surface water runoff from; or
• a change to onsite traffic pattern causes heavy vehicles to drive closer to bulk storage tanks.